Three Valentines from the IRS Webinar

February 14, 2018

In late 2017, the U.S. Department of the Treasury issued three sets of proposed partnership audit regulations that provide rules implementing many aspects of the provisions of the Bipartisan Budget Act of 2015. Most notably, one set of regulations allows for a Code Section 6226 "push-out" election to be effective in pushing adjustments through tiered partnership structures.